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landscaping at ERE. He testified that the landscaping created a
natural environment for the animals to thrive.
Mrs. Knudsen was the primary operator of ERE and devoted a
significant amount of time to it. Mrs. Knudsen also helped in
Dr. Knudsen’s medical practice and received wages for her
services. At one time, petitioners employed a manager of ERE to
help Mrs. Knudsen with the daily activities. After the manager
left around 2000, Mrs. Knudsen assumed all responsibilities for
the daily management of ERE.
Many of Mrs. Knudsen’s duties were demanding. She hand or
bottle fed baby animals several times a day. Mrs. Knudsen fed
the primates and kangaroos every day and spent about 45 minutes a
day feeding the birds in the breeder building. In addition, she
fed the kangaroos and the giraffe fresh fruit and produce three
times a week. During the winter, Mrs. Knudsen acclimated the
primates to the cold weather by letting them out during the day
and locking them up at night.
Mrs. Knudsen’s work at ERE was not always pleasurable. She
performed tasks such as cleaning stalls and cages, checking the
heaters in the middle of a blizzard, hand feeding the birds grub
worms, and disposing of animal carcasses. As a result of her
duties at ERE, Mrs. Knudsen sustained several injuries. In 1999,
she received a permanent scar on her left temple because of a
bird attack. In 2000, Mrs. Knudsen had surgery on her right
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